On 17 October 2019, the Finance Minister published draft legislation as part of Finance Bill 2019 for the implementation of European Union (EU) Directive 2018/822 regarding mandatory disclosure and exchange of cross-border tax arrangements (DAC6) to the Ireland’s legislature. As part of the Finance Bill 2019, the proposal will now face the legislative process, and may be amended before final enactment by 31 December 2019. If draft proposal implemented, the Irish DAC6 legislation will be broadly followed the EU Directive. This draft law includes some explanatory notes that describe the concepts and terms used in the Directive. The hallmarks for reportable transactions also are linked to Annex I of the Directive.
Under the mandatory disclosure rules, qualifying intermediaries (such as financial and tax advisers, lawyers, banks, accountants and domiciliation service providers) and under certain circumstances taxpayers need to report cross-border reportable arrangements to the relevant tax authorities from 1 July 2020.